340 Woodpecker Ridge

Santa Cruz, CA 95060

www.joby.aero

831.426.3733

RE: DOT/FAA Decision FAA-2016-5094-0003

Dear Brenda Robeson et al,

In response to your request for further clarification on how being granted our 333 exemption request 

serves the public interest:

As the FAA concluded in Exemption No. 11213: "The enhanced safety and reduced environmental impact 

achieved using a UA with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew... gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest."

Furthermore, our testing will take place in a 400 ft deep, decommissioned quarry owned by the 

company. This test area helps maintain a high level of safety exceeding the standard of an equivalent 

level of safety, and poses no burden on the national airspace as our flight testing activities will take 

place well below navigable airspace, and far from the person or property of non-participants.

Elaborating further on how this exemption request is in the public interest, we will describe the mission 

of our research and development using small unmanned systems, as well as explain why this work 

cannot be accomplished under part 107 and must occur under a part 333 exemption:

Joby Aviation is accelerating the evolution of electric propulsion technologies and civil aircraft designs 

towards a quieter, more efficient, safer, more affordable, more neighborly, and more environmentally 

friendly future. As our population grows and urban density increases, our need to move people and 

goods quickly, safely, and efficiently in and around urban environments is increasing. At the same time 

as the public need is increasing, the tolerance for noise and environmental pollution is decreasing.

We are losing the land occupied by runways and helipads to other developments, and often the reasons 

cited for this are the cost, pollution, and noise associated with internal combustion designs, as well as 

the amount of land required for conventional take-off and landing aircraft. The low carbon-footprint, 

quiet, cost effective electric VTOL technologies that we are developing are a critical piece of meeting 

these emerging needs, and will directly and significantly benefit the public at large in the years to come.

Before we embark on flight testing our full scale civil aircraft, we wish to operationally test our triple 

redundant flight computers, flight software, select avionics, communications links, flight termination 

systems, and sensor suites using the hardware which will fly on the full scale aircraft. Carrying this 
hardware on a small unmanned system requires the aircraft be larger than the 55 lb allowance of Part 

107 operations. 

Our exemption request being granted would allow us to continue our work towards the realization of 

these public interests by enabling us to perform flight testing of representative hardware and software 

on our unmanned quarter scale demonstrator before moving on to the full scale aircraft, which achieves 

the highest levels of safety and efficiency in bringing this transformative aircraft technology to the 

public.

Sincerely,

Brett Goldsmith

Joby Aviation

340 Woodpecker Ridge Santa Cruz,

CA 95060